Legal Opinion
S. Rossin & Sons v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided July 18, 1940No. 326, 327PublishedCited by 19 opinions
1Opinion of the Court
SWAN, Circuit Judge.
The ultimate question presented is whether the corporation realized taxable income in its fiscal year ending April 30, 1936 by transferring on its books a reserve for bad debts to a liquidation account and distributing its assets to its sole stockholder. By a majority of nine members to seven the Board held that it did.
There is no dispute as to the facts. S. Rossin & Sons, Inc., was incorporated in 1922. Its books were kept upon the accrual basis. In the tax return for its first fiscal year it elected to use the reserve method of accounting and deducting for bad debts, as…
2Cases cited6 opinions
- Putnam Nat. Bank v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1931
- Peabody Coal Co. v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Seventh Circuit · 1931
- G. M. Standifer Constr. Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
- Home Ice Cream & Ice Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Ganahl Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1930
1 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
- Geometric Stamping Co. v. CommissionerUnited States Tax Court · 1956
- Citizens Federal Savings and Loan Association of Cleveland v. United StatesCourt of Appeals for the Federal Circuit · 1961
- Fowler Bros. & Cox, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Barber v. CommissionerUnited States Tax Court · 1975
14 more not listed; retrieve them via the Exa API.